National Fire Protection Association. 1 Batterymarch Park, Quincy, MA Phone: Fax:
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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: Members of the NEC-Code Making Panel 11 FROM: Jean O Connor DATE: February 28, 2011 SUBJECT: NFPA 70 ROP TC Circulation Ballot (A2013 Cycle) The February 24, 2012 date for receipt of the NFPA 70 ROP letter ballot has passed. In accordance with the NFPA Regulations Governing Committee Projects, the attached circulation report contains the number of members eligible to vote, the names of principals whose ballots were not returned, and the reasons for negative votes for your review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. If you wish to change your vote, the change must be received at NFPA as soon as possible, however, no later than Thursday, March 8, Members who have not returned a ballot may do so at this time. Ballots or ballot changes should be sent to Jean O Connor via either to joconnor@nfpa.org or via fax to You may also mail your changes to the attention of Jean O Connor at NFPA, 1 Batterymarch Park, Quincy, MA The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Circulation Explanation Report
2 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 Entire Document (Log # 1170j ) 11-2 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 Entire Document (Log # 921j ) 11-3 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Adjustable-Speed Drive System (New) and (Log # 1492 ) 11-4 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Adjustable-Speed Drive System (New) and (Log # 1601 ) 11-5 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Control Circuit (New) and (Log # 1480 ) 11-6 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Hermetic Refrigerant Motor-Compressor (New) and (Log # 1603 ) 11-7 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Industrial Control Panel (New) and (Log # 1481 ) 11-8 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Motor Control Circuit (New) and (Log # 1602 ) 11-9 Eligible To Vote:14 Affirmative: 12 : 2 Abstain: 0 Not Returned: 0 409, 430, 440, 460, and 470 (Log # 3302 ) Powell, C. The committee action should have been accept. The primary function of the conductor presently defined as an "equipment grounding conductor" is actually a bonding function. The grounding electrode conductor grounds systems and equipment. Accepting this change will help increase usability and understanding of the associated requirements.
3 2 Smith, III, A. Similar proposals have been presented in the past and have been rejected. Reasons given often relate to cost, significant changes in documentation required, or the fact that knowledgeable people understand the use of this conductor. There is no justification for retaining an incorrect and potentially hazardous electrical installation just because this definition has been used in the NEC for many years. Costs associated with documentation changes should never be an argument where safety is concerned. Further, not all electrical practitioners are knowledgeable in the main intent of this conductor. The intent of the proposed change is to provide a descriptive name to a construction element that has resulted in much misunderstanding with possible hazardous operating conditions in electrical installations. The use of the term grounding implies that grounding is its principal function. Although grounding may be desirable, providing an effective fault current path (i.e. bonding) is and should be the emphasis. There are many who assert that a connection to a water pipe meets the needs of equipment grounding, however, this connection does not perform the necessary effective fault current path back to the source. There are two conductors described in the Code performing the same function but named differently. The bonding jumper is a short conductor that insures the electrical integrity of enclosure to raceway. The longer conductor, intended to provide a low impedance path to the source, is presently named a grounding conductor instead of its real function as a bonding conductor. Technically, the definition in Article 100 may be adequate for Panel members and those that teach. Practically, the definition is confusing if the terminology does not fit the function performed. The equipment bonding conductor, as it should be called, provides its primary function whether or not it is grounded. For a grounded system, it is grounded because the system is grounded. For an ungrounded system, it is grounded to limit the voltage due to a lightning strike or contact with a higher voltage system. Changing the name will assist in educating users of the Code as to why they are installing a conductor that needs to be continuous all of the way back to the source Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 991 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: and (4), Informational Note (Log # 2638c ) Affirmative with Comment Folz, S. The panel's action to "Accept in Principle" and eliminate the year of the document was in error. The action should have been to "Accept" Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Industrial Control Panel (Log # 1212 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 792 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 3322 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 362 ) Eligible To Vote:14 Affirmative: 10 : 4 Abstain: 0 Not Returned: (2) (Log # 2253 )
4 3 Cole, T. The logic behind requiring the disconnection/labeling of all power sources and their locations is similar to requiring the labeling of multiple source locations for services. The logic for rejecting this proposal was that it would be impractical to trace down multiple sources of power especially when dealing with PLC's. Control power for panels, when built properly, generally have the power sources built within them or are taken from a localized power panel. Requiring this additional marking would enhance safety for field personnel. The proper action should have been to Accept In Principle. Fahey, J. In Article (3) requires that the panel be labeled with number of sources of power, the change proposed in Proposal would add the location of the sources of power to complete the information needed to make the panel save for workers. The issue of the need for the label in Industrial applications could addresses with a revision providing relief for supervision etc. Fahey, R. This proposal should have been accepted with revisions to the proposed text to address Code Panel member concerns. This proposal, as well as 2 similar proposals, would provide an additional safety measure for the personnel which service these Industrial Control panels. This requirement would be similar to 408.4(B), the field identification requirement for supply source labeling of all switchboards and panelboards. The proposed requirement would be simple and the cost would be minimal. An exception to eliminate the need for labeling power sources for circuits 50 volts or less should have been added to the proposal. Saporita, V. For personnel safety reasons, this proposal should have been accepted in principle (3) should have been modified to read: "(3) The location of the power supply circuit disconnecting means. If the industrial control panel is supplied by more than one power source such that more than one disconnecting means is required to disconnect all power within the control panel, the marking shall indicate the location of each supply circuit disconnecting means." Eligible To Vote:14 Affirmative: 12 : 2 Abstain: 0 Not Returned: (3) (Log # 3215 ) Fahey, J. See my Explanation of Vote on Proposal Saporita, V. See my Explanation of Vote on Proposal Eligible To Vote:14 Affirmative: 11 : 3 Abstain: 0 Not Returned: (8) (New) (Log # 3236 ) Cole, T. See my Explanation of Vote on Proposal Fahey, J. See my Explanation of Vote on Proposal Saporita, V. See my Explanation of Vote on Proposal Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 183 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 430, Parts I through X (Log # 1033 )
5 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 1771 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Adjustable-Speed Drive System (Log # 1217 ) Eligible To Vote:14 Affirmative: 13 : 1 Abstain: 0 Not Returned: Motor Circuit Protector (Log # 762 ) Cole, T. The submitter is correct in trying to clarify what a Motor Circuit Protector is and how it should be used. There is confusion in the field as to how these breakers are used and because they are being used incorrectly, safety is compromised. There are even training organizations teaching field personnel incorrectly on the proper use of these types of breakers. The proposal should be Accept in Principle Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Motor Circuit Protector (New) (Log # 1763 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Valve Actuator Motor (VAM) Assemblies, Informational Note 2 (Log # 50 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 Table (Log # 2492 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A)(1) Exception No. 4 (New) (Log # 101 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: and (A) (Log # 1668 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 1157 ) 11-29a Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (G) (Log # 3507 ) 11-29b Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: , , , , , , (B)2, , (A), (A), (D), 440.6(A) Exception 2,
6 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (G) (Log # 3090 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 1787 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 2538 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: , Part III (Log # 2337 ) 11-33a Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (C), Informational Note (Log # 3508 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 1656 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 2338 ) 11-35a Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (C)(5) (Log # 3509 ) Affirmative with Comment Thompson, J. I support the original panel position and believe that the Panel Statement will be more effective, and descriptive to the Technical Correlating Committee and others with the added text shown below. Revise (C)(5) as follows; (5) Power Electronic Devices - Semiconductor fuses intended for the protection of electronic devices shall be permitted in lieu of devices listed in Table for power electronic devices, associated electromechanical devices (such as bypass contactors and isolation contactors) and conductors in a solid-state motor controller system provided as part of a listed combination motor controller. The marking for replacement fuses is provided adjacent to the fuses. Panel Statement - The proposed wording may confuse the reader since a fuse intended for the protection of electronic devices is being allowed to protect non-electronic devices such as contactors. Semiconductor fuses are evaluated to UL , the Standard for Semiconductor Fuses. Substituting Semiconductor Fuses for the proposed wording removes the potential confusion. Additionally, the statement provided as part of a listed combination motor controller was included since special purpose semiconductor fuses provided for branch circuit short circuit protection of solid-state motor controller systems, must be evaluated as part of a listed combination motor controller in order to ensure their proper use and coordination. Semiconductor fuses do not provide the full range of protection (from overcurrent through short circuit) that branch circuit type class rated fuses provide (eg, CC, J, T, RK5 etc) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (C)(7) (Log # 111 )
7 a Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (C)(4) (Log # 3510 ) 11-36b Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (D) (Log # 3511 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 1764 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) (Log # 2310 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) Exception No. 1(b) (Log # 865 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 2257 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (C) and Informational Note (New) (Log # 51 ) 11-41a Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 3512 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 3323 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 Table (D) (Log # 361 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) (Log # 2258 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception No. 1 (Log # 291 )
8 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) Exception No. 1 and Exception No. 3(a) (Log # 866 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) Exception No. 3(b) (Log # 477 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) Exception No. 3 (b) (Log # 292 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) Exception to (1) and (2) (Log # 293 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) Exception to (1) and (2) (Log # 478 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B)(2), Informational Note 1 (Log # 1873 ) Eligible To Vote:14 Affirmative: 13 : 1 Abstain: 0 Not Returned: (B)(2) Exception (b) (Log # 692 ) Fahey, J. The requirements work well with employees of the owners but may not be as effective with contractor workers not as well versed in employer education as direct employees. The could put all at risk. The relief to the employer should not increase the danger to employees Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 867 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception No. 1 (Log # 294 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 3324 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 104 )
9 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) (Log # 2322 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A)(2) (Log # 184 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 3091 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception (New) (Log # 2642 ) 11-60a Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: and (Log # 3506 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 430, Part XI (Log # 1032 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 2793 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: and (Log # 2826 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 295 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 3356 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 841 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 842 )
10 Eligible To Vote:14 Affirmative: 13 : 1 Abstain: 0 Not Returned: (Log # 843 ) Missildine, Jr., J. The 150 volts to ground requirement is a determination of voltage class and not a determination of hazard level. OSHA and NFPA 70E are work practice documents and are being improperly applied in the substantiation Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: , Informational Note (New) (Log # 1963 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 1814 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 2040 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 2369 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 2397 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B) (Log # 2852 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Adjustable Speed Drive, Adjustable Speed Drive System, Branch-Circuit Selection Current, Hermetic Refrigerant Motor Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Branch-Circuit Selection Current (Log # 1218 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 Table 440.3(D) (Log # 2493 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 782 )
11 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: and (Log # 1669 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception (New) (Log # 783 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (C) (Log # 784 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception No. 2 (New) (Log # 785 ) Eligible To Vote:14 Affirmative: 11 : 3 Abstain: 0 Not Returned: (Log # 1622 ) Missildine, Jr., J. Requiring a conductor for equipment ground rather than use of conduit or other means described in is not a substitute for proper conduit application, installation or maintenance. Also, this change would only correct the stated problem for air conditioning and refrigeration equipment, not all rooftop units such as air handling units which would be covered by Article 430. This does not preclude the voluntary use of a conductor for the equipment ground. Powell, C. The panel action was appropriate to remediate an equipment grounding problem that exists in residential and commercial air conditioning installations. The supporting documentation identified that a problem exists with these residential and commercial installations but there was no evidence presented that the existing practices in industrial installations should be modified by this new code section. Typical industrial refrigeration units involve large motors whose installation does not require a local disconnect switch, ( Exception No. 1), and therefore the substantiation does not apply. We request the following exception: Exception: Where Air Conditioning or Refrigerating Equipment is part of an industrial, commercial, or institutional installation operating under conditions of maintenance and supervision that ensure that only qualified persons monitor and supervise the system, LFMC shall be permitted to be used as an equipment grounding conductor when installed in accordance with (6). Additionally, adding this exception will be consistent with Panel 8's actions on Wright, J. This proposal should be rejected. Nothing in the substantiation, in the CPSC report or in the report of the Chicago incident indicates the wiring method was the cause of the electrocution. The photos enclosed with the substantiation do not show that EMT was used. The CPSC report is dated 2002 and only shows the number of consumer product-related electrocutions by specific products involved, not the specific cause. The report shows a greater number of electrocutions were related to other components of the installed household wiring than to the wiring method. In the case of damaged or exposed wiring, the exact nature of the wiring was unspecified. The use of a supplemental equipment grounding conductor should be a design decision based on the wiring method to be used and the unique installation environment in which the equipment is being installed. The Georgia Tech research study on grounding validates that EMT is a proven equipment grounding conductor when installed in accordance with the NEC and with either set-screw or compression type fittings. Affirmative with Comment Fahey, R. It is agreed that the equipment grounding conductor is necessary, although it is recommended that the Technical Correlating Committee correlate this requirement with Code-Making Panel 8 and Code-Making Panel 11. It is also recommended this proposal be evaluated by Code-Making Panel 5 for relocation into , eliminating the requirements in (B), and
12 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 3325 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 786 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception No. 1 (Log # 296 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: Exception No. 1 (Log # 479 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 787 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (New) (Log # 788 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 789 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (Log # 790 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (A) and (B) (Log # 148 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 460, Part I (Log # 1035 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 460, Part II (Log # 1036 ) Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: (B)(2) (Log # 868 )
13 Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 470, Part I (Log # 1037 ) Eligible To Vote:14 Affirmative: 13 : 1 Abstain: 0 Not Returned: (Log # 115 ) Cole, T. According to the Style Manual panels are encouraged to use the same section numbers for the same purposes within articles covering similar subjects. If one were to look at other articles, the.2's are typically used for definitions. The submitter is correct and the panel should have voted to Accept in Principal and reassign the current.2 to another available number Eligible To Vote:14 Affirmative: 14 : 0 Abstain: 0 Not Returned: 0 470, Part II (Log # 1038 )
National Fire Protection Association. 1 Batterymarch Park, Quincy, MA Phone: Fax:
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